We have an affiliate that has asked that our insurance agent handle paperwork to establish HSA accounts should the opportunity arise. The arrangement will be formalized in writing by the parties, including agreement that CIP will be initially performed by Agent on behalf of bank. Can anyone think of any special requirements that may impact this situation?

I am primarily concerned that the sale of a high deductible insurance policy to an employer with subsequent marketing of HSA accounts to employees could present a problem. Do we need to change insurance disclosure to add reference that an HSA account may have been suggested by Agent; however, individual was informed of HSA options and chose to obtain from bank.

I'm not clear on who the agent works for and where they work. I would be concerned about a non-bank employee opening accounts for the bank, and if they work off site then I would be concerned about possible branching violations.

I have a similar question. Is anyone having an insurance agent hand out bank applications for a HSA? Since this agency is in our bank building (independent of the bank) do they need to give out any specific disclosures? We have the agency give out the Consumer Sales Disclosure for their products. Any advice is appreciated.

Please be aware that you will have to track all of these deposits gathered through the insurance agent as brokered deposits. The call report instruction read:

For purposes of these reports, the term deposit broker includes:

(1) any person engaged in the business of placing deposits, or facilitating the placement of deposits, of third parties with insured depository institutions or the business of placing deposits with insured depository institutions for the purpose of selling interests in those deposits to third parties.

The insurance agent would be giving the application only. The agent would not be opening the account. Does this make a difference. The paperwork to open the account and the deposit would be made with a bank employee.